Carolyn Cooper v. General Motors LLC et al

Filing 28

STIPULATED PROTECTIVE ORDER by Magistrate Judge Kenly Kiya Kato re Stipulation for Protective Order 27 . (see document for details). (et)

1 Vince M. Verde, CA Bar No. 202472

[e-mail]

2 Ogletree, Deakins, Nash, Smoak & Stewart, P.C.

Park Tower, Fifteenth Floor

3 695 Town Center Drive

Costa Mesa, CA 92626

4 Telephone: [phone]
5

Facsimile: 714-754-1298
Andrew J. Deddeh CA Bar No. 272638

6 [e-mail]

OGLETREE, DEAKINS, NASH,

7 SMOAK & STEWART, P.C.

4660 La Jolla Village Drive, Suite 900

8 San Diego, CA 92122

Telephone: [phone]
858-652-3101

9 Facsimile:

10 Attorneys for Defendant GENERAL MOTORS LLC
11 Young W. Ryu, CA Bar No. 266372

[e-mail]

12 Joshua Park, CA Bar No. 299572

[e-mail]

13 Kee Seok Mah, CA Bar No. 345736

[e-mail]

14 Zachariah E. Moura, CA Bar No. 279508

[e-mail]

15 LOYR, APC

1055 W. 7th Street, Suite 2290
16 Los Angeles, CA 90017
Telephone: [phone]
17 Facsimile: 800-576-1170
18 Attorneys for Plaintiff CAROLYN COOPER
19

UNITED STATES DISTRICT COURT

20

CENTRAL DISTRICT OF CALIFORNIA

21 CAROLYN COOPER, an individual,

Case No. 5:23-cv-00328 JGB-KK

22

STIPULATED PROTECTIVE
ORDER

23

Plaintiff,
v.

24

GENERAL MOTORS LLC, a
25 Delaware limited liability company; and
DOES 1 through 50, inclusive,
26

Complaint Filed: October 19, 2022
Removed: February 24, 2023
District Judge: Hon. Jesus G. Bernal
Magistrate Judge: Hon. Kenly Kiya Kato

Defendants.

27
28
Case No. 5:23-cv-00328 JGB-KK
STIPULATED PROTECTIVE ORDER

1

1.

A.

PURPOSES AND LIMITATIONS

2

Discovery in this action is likely to involve production of confidential,

3

proprietary, or private information for which special protection from public disclosure

4

and from use for any purpose other than prosecuting this litigation may warranted.

5

Accordingly, the parties hereby stipulate to and petition the Court to enter the

6

following Stipulated Protective Order. The parties acknowledge that this Order does

7

not confer blanket protections on all disclosures or responses to discovery and that the

8

protection it affords from public disclosure and use extends only to the limited

9

information or items that are entitled to confidential treatment under the applicable

10

legal principles. The parties further acknowledge, as set forth in Section 12.3, below,

11

that this Stipulated Protective Order does not entitle them to file confidential

12

information under seal; Civil Local Rule 79-5 sets forth the procedures that must be

13

followed and the standards that will be applied when a party seeks permission from

14

the court to file material under seal.

15

B.

GOOD CAUSE STATEMENT

16

This action is likely to involve trade secrets, customer and pricing lists and other

17

valuable research, development, commercial, financial, technical and/or proprietary

18

information for which special protection from public disclosure and from use for any

19

purpose other than prosecution of this action is warranted. Such confidential and

20

proprietary materials and information consist of, among other things, confidential

21

business or financial information, information regarding confidential business

22

practices, or other confidential research, development, or commercial information

23

(including information implicating privacy rights of third parties), information

24

otherwise generally unavailable to the public, or which may be privileged or otherwise

25

protected from disclosure under state or federal statutes, court rules, case decisions, or

26

common law. Accordingly, to expedite the flow of information, to facilitate the prompt

27

resolution of disputes over confidentiality of discovery materials, to adequately protect

28

information the parties are entitled to keep confidential, to ensure that the parties are
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STIPULATED PROTECTIVE ORDER

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permitted reasonable necessary uses of such material in preparation for and in the

2

conduct of trial, to address their handling at the end of the litigation, and serve the ends

3

of justice, a protective order for such information is justified in this matter. It is the

4

intent of the parties that information will not be designated as confidential for tactical

5

reasons and that nothing be so designated without a good faith belief that it has been

6

maintained in a confidential, non-public manner, and there is good cause why it should

7

not be part of the public record of this case.

8

2.

9

DEFINITIONS
2.1

Action: This pending federal law suit entitled Carolyn Cooper v. General

10

Motors, LLC situated in the U.S. District Court Central District of California Case No.

11

5:23-cv-00328 JGB-KK.

12
13
14

2.2

Challenging Party: a Party or Non-Party that challenges the designation

of information or items under this Order.
2.3

“CONFIDENTIAL” Information or Items: information (regardless of

15

how it is generated, stored or maintained) or tangible things that qualify for protection

16

under Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause

17

Statement.

18
19
20

2.4

Counsel: Outside Counsel of Record and House Counsel (as well as their

support staff).
2.5

Designating Party: a Party or Non-Party that designates information or

21

items that it produces in disclosures or in responses to discovery as

22

“CONFIDENTIAL.”

23

2.6

Disclosure or Discovery Material: all items or information, regardless of

24

the medium or manner in which it is generated, stored, or maintained (including,

25

among other things, testimony, transcripts, and tangible things), that are produced or

26

generated in disclosures or responses to discovery in this matter.

27
28

2.7

Expert: a person with specialized knowledge or experience in a matter

pertinent to the litigation who has been retained by a Party or its counsel to serve as
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STIPULATED PROTECTIVE ORDER

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an expert witness or as a consultant in this Action.
2.8

2

House Counsel: attorneys who are employees of a party to this Action.

3

House Counsel does not include Outside Counsel of Record or any other outside

4

counsel.
2.9

5
6

Non-Party: any natural person, partnership, corporation, association, or

other legal entity not named as a Party to this action.

7

2.10 Outside Counsel of Record: attorneys who are not employees of a party

8

to this Action but are retained to represent or advise a party to this Action and have

9

appeared in this Action on behalf of that party or are affiliated with a law firm which

10

has appeared on behalf of that party, and includes support staff.

11

2.11 Party: any party to this Action, including all of its officers, directors,

12

employees, consultants, retained experts, and Outside Counsel of Record (and their

13

support staffs).
2.12 Producing Party: a Party or Non-Party that produces Disclosure or

14
15

Discovery Material in this Action.

16

2.13 Professional Vendors: persons or entities that provide litigation support

17

services (e.g., photocopying, videotaping, translating, preparing exhibits or

18

demonstrations, and organizing, storing, or retrieving data in any form or medium) and

19

their employees and subcontractors.
2.14 Protected Material: any Disclosure or Discovery Material that is

20
21

designated as “CONFIDENTIAL.”
2.15 Receiving Party: a Party that receives Disclosure or Discovery Material

22
23

from a Producing Party.

24

3.

SCOPE

25

The protections conferred by this Stipulation and Order cover not only Protected

26

Material (as defined above), but also (1) any information copied or extracted from

27

Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected

28

Material; and (3) any testimony, conversations, or presentations by Parties or their
3
STIPULATED PROTECTIVE ORDER

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Counsel that might reveal Protected Material. Any use of Protected Material at trial

2

shall be governed by the orders of the trial judge. This Order does not govern the use

3

of Protected Material at trial.

4

4.

DURATION

5

Once a case proceeds to trial, all of the information that was designated as

6

confidential or maintained pursuant to this protective order becomes public if it was

7

used in trial and will be presumptively available to all members of the public, including

8

the press, unless compelling reasons supported by specific factual findings to proceed

9

otherwise are made to the trial judge in advance of the trial. See Kamakana v. City and

10

County of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good

11

cause” showing for sealing documents produced in discovery from “compelling

12

reasons” standard when merits-related documents are part of court record).

13

Accordingly, the terms of this protective order do not extend beyond the

14

commencement of the trial as to any CONFIDENTIAL documents published to the

15

jury or otherwise made a part of the public record of the trial. This does not extend to

16

any other information designated CONFIDENTIAL. eEven after final disposition of

17

this litigation, the confidentiality obligations imposed by this Order shall remain in

18

effect until a Designating Party agrees otherwise in writing or a court order otherwise

19

directs. Final disposition shall be deemed to be the later of (1) dismissal of all claims

20

and defenses in this Action, with or without prejudice; and (2) final judgment herein

21

after the completion and exhaustion of all appeals, rehearings, remands, trials, or

22

reviews of this Action, including the time limits for filing any motions or applications

23

for extension of time pursuant to applicable law.

24

5.

25

DESIGNATING PROTECTED MATERIAL
5.1

Exercise of Restraint and Care in Designating Material for Protection.

26

Each Party or Non-Party that designates information or items for protection under this

27

Order must take care to limit any such designation to specific material that qualifies

28

under the appropriate standards. The Designating Party must designate for protection
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STIPULATED PROTECTIVE ORDER

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only those parts of material, documents, items, or oral or written communications that

2

qualify so that other portions of the material, documents, items, or communications

3

for which protection is not warranted are not swept unjustifiably within the ambit of

4

this Order.

5

Mass, indiscriminate, or routinized designations are prohibited. Designations

6

that are shown to be clearly unjustified or that have been made for an improper purpose

7

(e.g., to unnecessarily encumber the case development process or to impose

8

unnecessary expenses and burdens on other parties) may expose the Designating

9

Party to sanctions.

10

If it comes to a Designating Party’s attention that information or items that it

11

designated for protection do not qualify for protection, that Designating Party must

12

promptly notify all other Parties that it is withdrawing the inapplicable designation.

13

5.2

Manner and Timing of Designations. Except as otherwise provided in this

14

Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated

15

or ordered, Disclosure or Discovery Material that qualifies for protection under this

16

Order must be clearly so designated before the material is disclosed or produced.

17

Designation in conformity with this Order requires:

18

(a)

for information in documentary form (e.g., paper or electronic

19

documents, but excluding transcripts of depositions or other pretrial or trial

20

proceedings), that the Producing Party affix at a minimum, the legend

21

“CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that

22

contains protected material. If only a portion or portions of the material on a page

23

qualifies for protection, the Producing Party also must clearly identify the protected

24

portion(s) (e.g., by making appropriate markings in the margins).

25

A Party or Non-Party that makes original documents available for inspection

26

need not designate them for protection until after the inspecting Party has indicated

27

which documents it would like copied and produced. During the inspection and before

28

the designation, all of the material made available for inspection shall be deemed
5
STIPULATED PROTECTIVE ORDER

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“CONFIDENTIAL.” After the inspecting Party has identified the documents it wants

2

copied and produced, the Producing Party must determine which documents, or

3

portions thereof, qualify for protection under this Order. Then, before producing the

4

specified documents, the Producing Party must affix the “CONFIDENTIAL legend”

5

to each page that contains Protected Material. If only a portion or portions of the

6

material on a page qualifies for protection, the Producing Party also must clearly

7

identify the protected portion(s) (e.g., by making appropriate markings in the margins).
(b)

8
9
10

for testimony given in depositions that the Designating Party identify the

Disclosure or Discovery Material on the record, before the close of the deposition all
protected testimony.
(c)

11

for information produced in some form other than documentary and for

12

any other tangible items, that the Producing Party affix in a prominent place on the

13

exterior of the container or containers in which the information is stored the legend

14

“CONFIDENTIAL.” If only a portion or portions of the information warrants

15

protection, the Producing Party, to the extent practicable, shall identify the protected

16

portion(s).
5.3

17

Inadvertent Failures to Designate. If timely corrected, an inadvertent

18

failure to designate qualified information or items does not, standing alone, waive the

19

Designating Party’s right to secure protection under this Order for such material. Upon

20

timely correction of a designation, the Receiving Party must make reasonable efforts

21

to assure that the material is treated in accordance with the provisions of this Order.

22

6.

CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1

23

Timing of Challenges. Any Party or Non-Party may challenge a

24

designation of confidentiality at any time that is consistent with the Court’s Scheduling

25

Order.
6.2

26

Meet and Confer. The Challenging Party shall initiate the dispute

27

resolution process under Local Rule 37.1 et seq.

28

///
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STIPULATED PROTECTIVE ORDER

Case No. 5:23-cv-00328 JGB-KK

6.3

1

The burden of persuasion in any such challenge proceeding shall be on

2

the Designating Party. Frivolous challenges, and those made for an improper purpose

3

(e.g., to harass or impose unnecessary expenses and burdens on other parties) may

4

expose the Challenging Party to sanctions. Unless the Designating Party has waived

5

or withdrawn the confidentiality designation, all parties shall continue to afford the

6

material in question the level of protection to which it is entitled under the Producing

7

Party’s designation until the Court rules on the challenge.

8

7.

9

ACCESS TO AND USE OF PROTECTED MATERIAL
7.1

Basic Principles. A Receiving Party may use Protected Material that is

10

disclosed or produced by another Party or by a Non-Party in connection with this

11

Action only for prosecuting, defending, or attempting to settle this Action. Such

12

Protected Material may be disclosed only to the categories of persons and under the

13

conditions described in this Order. When the Action has been terminated, a Receiving

14

Party must comply with the provisions of section 13 below (FINAL DISPOSITION).

15

Protected Material must be stored and maintained by a Receiving Party at a

16

location and in a secure manner that ensures that access is limited to the persons

17

authorized under this Order.

18

7.2

Disclosure of “CONFIDENTIAL” Information or Items. Unless

19

otherwise ordered by the court or permitted in writing by the Designating Party, a

20

Receiving Party may disclose any information or item designated

21

“CONFIDENTIAL” only to:

22

(a)

the Receiving Party’s Outside Counsel of Record in this Action, as well

23

as employees of said Outside Counsel of Record to whom it is reasonably necessary

24

to disclose the information for this Action;

25
26
27
28

(b)

the officers, directors, and employees (including House Counsel) of the

Receiving Party to whom disclosure is reasonably necessary for this Action;
(c)

Experts (as defined in this Order) of the Receiving Party to whom

disclosure is reasonably necessary for this Action and who have signed the
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STIPULATED PROTECTIVE ORDER

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“Acknowledgment and Agreement to Be Bound” (Exhibit A);

2

(d)

the court and its personnel;

3

(e)

court reporters and their staff;

4

(f)

professional jury or trial consultants, mock jurors, and Professional

5

Vendors to whom disclosure is reasonably necessary for this Action and who have

6

signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
(g)

7
8

the author or recipient of a document containing the information or a

custodian or other person who otherwise possessed or knew the information;
(h)

9

during their depositions, witnesses ,and attorneys for witnesses, in the

10

Action to whom disclosure is reasonably necessary provided: (1) the deposing party

11

requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will

12

not be permitted to keep any confidential information unless they sign the

13

“Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed

14

by the Designating Party or ordered by the court. Pages of transcribed deposition

15

testimony or exhibits to depositions that reveal Protected Material may be separately

16

bound by the court reporter and may not be disclosed to anyone except as permitted

17

under this Stipulated Protective Order; and
(i)

18

any mediator or settlement officer, and their supporting personnel,

19

mutually agreed upon by any of the parties engaged in settlement discussions.

20

8.

PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN

21

OTHER LITIGATION

22

If a Party is served with a subpoena or a court order issued in other litigation

23

that compels disclosure of any information or items designated in this Action as

24

“CONFIDENTIAL,” that Party must:

25
26
27
28

(a)

promptly notify in writing the Designating Party. Such notification shall

include a copy of the subpoena or court order;
(b)

promptly notify in writing the party who caused the subpoena or order to

issue in the other litigation that some or all of the material covered by the subpoena or
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STIPULATED PROTECTIVE ORDER

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order is subject to this Protective Order. Such notification shall include a copy of this

2

Stipulated Protective Order; and
(c)

3

cooperate with respect to all reasonable procedures sought to be pursued

4

by the Designating Party whose Protected Material may be affected. If the Designating

5

Party timely seeks a protective order, the Party served with the subpoena or court order

6

shall not produce any information designated in this action as “CONFIDENTIAL”

7

before a determination by the court from which the subpoena or order issued, unless

8

the Party has obtained the Designating Party’s permission. The Designating Party shall

9

bear the burden and expense of seeking protection in that court of its confidential

10

material and nothing in these provisions should be construed as authorizing or

11

encouraging a Receiving Party in this Action to disobey a lawful directive from

12

another court.

13

9.

A

NON-PARTY’S

PROTECTED

14

PRODUCED IN THIS LITIGATION

15

(a)

MATERIAL

SOUGHT

TO

BE

The terms of this Order are applicable to information produced by a Non-

16

Party in this Action and designated as “CONFIDENTIAL.” Such information

17

produced by Non-Parties in connection with this litigation is protected by the remedies

18

and relief provided by this Order. Nothing in these provisions should be construed as

19

prohibiting a Non-Party from seeking additional protections.

20

(b)

In the event that a Party is required, by a valid discovery request, to

21

produce a Non-Party’s confidential information in its possession, and the Party is

22

subject to an agreement with the Non-Party not to produce the Non-Party’s

23

confidential information, then the Party shall:

24

(1)

promptly notify in writing the Requesting Party and the Non-Party

25

that some or all of the information requested is subject to a confidentiality agreement

26

with a Non-Party;

27
28

(2)

promptly provide the Non-Party with a copy of the Stipulated

Protective Order in this Action, the relevant discovery request(s), and a reasonably
9
STIPULATED PROTECTIVE ORDER

Case No. 5:23-cv-00328 JGB-KK

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specific description of the information requested; and
(3)

2
3

make the information requested available for inspection by the

Non-Party, if requested.
(c)

4

If the Non-Party fails to seek a protective order from this court within 14

5

days of receiving the notice and accompanying information, the Receiving Party may

6

produce the Non-Party’s confidential information responsive to the discovery request.

7

If the Non-Party timely seeks a protective order, the Receiving Party shall not produce

8

any information in its possession or control that is subject to the confidentiality

9

agreement with the Non-Party before a determination by the court. Absent a court

10

order to the contrary, the Non-Party shall bear the burden and expense of seeking

11

protection in this court of its Protected Material.

12

10.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

13

If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed

14

Protected Material to any person or in any circumstance not authorized under this

15

Stipulated Protective Order, the Receiving Party must immediately (a) notify in

16

writing the Designating Party of the unauthorized disclosures, (b) use its best efforts

17

to retrieve all unauthorized copies of the Protected Material, (c) inform the person or

18

persons to whom unauthorized disclosures were made of all the terms of this Order,

19

and (d) request such person or persons to execute the “Acknowledgment and

20

Agreement to Be Bound” that is attached hereto as Exhibit A.

21

11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

22

PROTECTED MATERIAL

23

When a Producing Party gives notice to Receiving Parties that certain

24

inadvertently produced material is subject to a claim of privilege or other protection,

25

the obligations of the Receiving Parties are those set forth in Federal Rule of Civil

26

Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure

27

may be established in an e-discovery order that provides for production without prior

28

privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
10
STIPULATED PROTECTIVE ORDER

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parties reach an agreement on the effect of disclosure of a communication or

2

information covered by the attorney-client privilege or work product protection, the

3

parties may incorporate their agreement in the stipulated protective order submitted to

4

the court.

5

12.

12.1 Right to Further Relief. Nothing in this Order abridges the right of any

6
7

MISCELLANEOUS

person to seek its modification by the Court in the future.

8

12.2 Right to Assert Other Objections. By stipulating to the entry of this

9

Protective Order no Party waives any right it otherwise would have to object to

10

disclosing or producing any information or item on any ground not addressed in this

11

Stipulated Protective Order. Similarly, no Party waives any right to object on any

12

ground to use in evidence of any of the material covered by this Protective Order.

13

12.3 Filing Protected Material. A Party that seeks to file under seal any

14

Protected Material must comply with Civil Local Rule 79-5. Protected Material may

15

only be filed under seal pursuant to a court order authorizing the sealing of the specific

16

Protected Material at issue. If a Party's request to file Protected Material under seal is

17

denied by the court, then the Receiving Party may file the information in the public

18

record unless otherwise instructed by the court.

19

13.

FINAL DISPOSITION

20

After the final disposition of this Action, as defined in paragraph 4, within 60

21

days of a written request by the Designating Party, each Receiving Party must return

22

all Protected Material to the Producing Party or destroy such material. As used in this

23

subdivision, “all Protected Material” includes all copies, abstracts, compilations

24

summaries, and any other format reproducing or capturing any of the Protected

25

Material. Whether the Protected Material is returned or destroyed, the Receiving Party

26

must submit a written certification to the Producing Party (and, if not the same person

27

or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by

28

category, where appropriate) all the Protected Material that was returned or destroyed
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STIPULATED PROTECTIVE ORDER

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and (2)affirms that the Receiving Party has not retained any copies, abstracts,

2

compilations, summaries or any other format reproducing or capturing any of the

3

Protected Material. Notwithstanding this provision, Counsel are entitled to retain an

4

archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts,

5

legal memoranda, correspondence, deposition and trial exhibits, expert reports,

6

attorney work product, and consultant and expert work product, even if such materials

7

contain Protected Material. Any such archival copies that contain or constitute

8

Protected Material remain subject to this Protective Order as set forth in

9

Section 4 (DURATION).

10

14.

Any violation of this Order may be punished by any and all appropriate

11

measures including, without limitation, contempt proceedings and/or monetary

12

sanctions.

13
14

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

15
16

DATED: October 20, 2023

LOYR, APC

17

/s/ Zachariah E Moura
Young W. Ryu
Joshua Park
Kee Seok Mah
Zachariah E. Moura

18
19
20
21

Attorneys for Plaintiff, Carolyn Cooper

22
23
24
25
26
27
28

DATED: October 20, 2023

OGLETREE, DEAKINS, NASH, SMOAK &
STEWART, P.C.
/s/ Andrew J. Deddeh
Vince M. Verde
Andrew J. Deddeh
Attorneys for Defendant, General Motors LLC
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EXHIBIT A

2

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3

I, __________________________________[print or type full name], of

4

___________________________________________ [print or type full address],

5

declare under penalty of perjury that I have read in its entirety and understand the

6

Stipulated Protective Order that was issued by the United States District Court for the

7

Central District of California on [date] in the case of Carolyn Cooper v. General

8

Motors, LLC, Case No. 5:23-cv-00328 JGB-KK. I agree to comply with and to be

9

bound by all the terms of this Stipulated Protective Order and I understand and

10

acknowledge that failure to so comply could expose me to sanctions and punishment

11

in the nature of contempt. I solemnly promise that I will not disclose in any manner

12

any information or item that is subject to this Stipulated Protective Order to any person

13

or entity except in strict compliance with the provisions of this Order.

14

I further agree to submit to the jurisdiction of the United States District Court for the

15

Central District of California for the purpose of enforcing the terms of this Stipulated

16

Protective Order, even if such enforcement proceedings occur after termination of this

17

action. I hereby appoint __________________________ [print or type full name] of

18

_______________________________________ [print or type full address and

19

telephone number] as my California agent for service of process in connection with

20

this action or any proceedings related to enforcement of this Stipulated Protective

21

Order.

22

Date: ______________________________________

23

City and State where sworn and signed: _________________________________

24
25

Printed name: _______________________________

26
27

Signature: __________________________________

28

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ATTACHMENT 1

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Case No. 5:23-cv-00328 JGB-KK
STIPULATED PROTECTIVE ORDER

Vince M. Verde, CA Bar No. 202472
[e-mail]
2 Ogletree, Deakins, Nash, Smoak & Stewart, P.C.
Park Tower, Fifteenth Floor
3 695 Town Center Drive
Costa Mesa, CA 92626
4 Telephone: [phone]
Facsimile: 714-754-1298
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Andrew J. Deddeh CA Bar No. 272638
[e-mail]
OGLETREE, DEAKINS, NASH,
7 SMOAK & STEWART, P.C.
4660 La Jolla Village Drive, Suite 900
8 San Diego, CA 92122
Telephone: [phone]
9 Facsimile: 858-652-3101
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Attorneys for Defendant GENERAL MOTORS LLC

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Young W. Ryu, CA Bar No. 266372
[e-mail]
Joshua Park, CA Bar No. 299572
[e-mail]
Kee Seok Mah, CA Bar No. 345736
[e-mail]
Zachariah E. Moura, CA Bar No. 279508
[e-mail]
LOYR, APC
1055 W. 7th Street, Suite 2290
Los Angeles, CA 90017
Telephone: [phone]
Facsimile: 800-576-1170

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Attorneys for Plaintiff CAROLYN COOPER

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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CAROLYN COOPER, an individual,

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Case No. 5:23-cv-00328 JGB-KK
ORDER

Plaintiff,

Complaint Filed: October 19, 2022
Removed: February 24, 2023

v.

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GENERAL MOTORS LLC, a
25 Delaware limited liability company; and
DOES 1 through 50, inclusive,
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District Judge: Hon. Jesus G. Bernal
Magistrate Judge: Hon. Kenly Kiya Kato

Defendants.

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Case No. 5:23-cv-00328 JGB-KK
ORDER

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The Court has read and considered the Parties’ Stipulated Protective Order. The

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matter having been considered, and good cause therefore having been shown, IT IS

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SO ORDERED.

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October 23, 2023
DATED:________________________

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__________________________________
Hon. Kenly Kiya Kato
United States Magistrate Judge

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ORDER

Case No. 5:23-cv-00328 JGB-KK